Monday, December 22, 2008

New Contaminant Found at Target Superfund Site

Target Cuts Deal with EPA to Proceed with Project on January 5, 2009

The Vanguard has learned that a group that monitors the Superfund site at the new Target location has discovered potentially a new source of contamination. This source was discovered at testing wells on the Target site.

According to the group, Frontier Fertilizer Superfund Oversight Group (FFSOG), EPA and Target have known that Trichloropropane (TCP) was detected in a sample taken just northeast of where the store would be. TCP is listed by the International Agency for Research on Cancer (part of the World Health Organization) as "probably carcinogenic to humans." While TCP has been detected before at the Frontier Fertilizer site, this location is outside the current treatment area.

The level at which TCP was found was approximately 3000 times the level at which it would trigger action.

According to the group:

"The general movement of the groundwater is generally northeast from the detection site: toward existing homes. The EPA needs to determine whether this contamination is part of the current plume or a new source of contamination on the Target site. In order for that determination to be made, more sampling at different locations within the store footprint must be done, requiring a halt to construction until the testing is complete."

Those who remember the Target campaign will recall of one of the concerns about the 2nd street location had to do with its proximity to the Target site. During the course of the campaign, controversy arose when the Yes on Measure K campaign purported that the EPA was in support of building a Target at this location.

According to FFSOG's website:

From 1972 until 1983, Frontier Fertilizer personnel dumped residual pesticides from drums and tanker trucks onto the ground and into unlined pits on the property. These pesticides leaked into the groundwater and now form a contaminated plume lying between 30 and 130 feet below ground surface and reaching over 800 feet north of the original disposal basin. Soil on the site in the vicinity of the disposal basin is also highly contaminated.

The public became aware of the site in 1983 when a dog fell into a pit on the property and died from pesticide poisoning.

In 1994, the Federal Environmental Protection Agency (EPA) placed the Frontier Fertilizer site on the National Priorities List (NPL) and declared it a Federal Superfund Site. Since 1994, EPA has studied the site and repaired, upgraded and expanded an existing contaminant monitoring and removal system put in place by the State. EPA is currently in the process of developing and implementing a final remedy for treatment of the groundwater and soil contamination.

Target has to move several of EPA's monitoring wells that are located under what will be the footprint for the store.

According to the President of FFSOG, Pam Nieberg:

"The wells that were to be replaced were important wells that were monitoring just beyond the eastern extent of the groundwater plume of contamination. They were there to tell us if the plume was still moving in that direction--not being adequately contained by the pump and treat system extraction system."

There has been considerable discussion between members of FFSOG, the EPA, and Target as to whether Target needs to do more sampling to determine where the TCP is coming from.

Target is arguing that they need to stick to their schedule which has them pouring a slab for the store January 5. The TCP they believe is a fluke as it has not been detected in other samplings. They do not have the funding to do more sampling.

Other members of the group however argue that sampling is imperative and they do not buy that Target lacks funding for sampling.

According to Ms. Nieberg:

"One issue was that if it came from the source area and was part of the plume that EPA has been cleaning up, then it would be EPA's job to investigate it and capture it in the P and T system. However, if it was not from the source area, it was a new contaminant site on Target's property and Target would have to investigate it and clean it up. Also, if it was from the source area, which is southeast of the Target footprint, then that would indicate that there might be a plume or finger of contamination running under the Target footprint. "

The issue here was that if there was a plume of TCP under the footprint, because TCP is volatile, it could enter the building through the cement slab and pose a risk to workers in the store. Target proposed engineering controls. A layer of gravel covered by a membrane vapor barrier under the slab. Piping would run from the gravel layer up through the walls of the store and vent to the outside.

EPA management and attorneys met with Target representatives and reached an agreement to allow Target to move ahead but they would have to institute the engineering controls.

However, members of FFSOG strongly argued that sampling should be done prior to the pouring of the slab to determine the extent of the problem.

In a letter to EPA Project Manager Bonnie Arthur, Pam Nieberg wrote:

"I am concerned that Target is planning to move ahead with construction prior to further evaluation of the extent of the TCP contamination. I expressed these concerns to the FFSOG Board and community members in attendance and they believe that further sampling should occur to determine the extent and source of the TCP contamination prior to further construction at the Target site."

She continued:

"You stated in your November 24th response that EPA can require Target to investigate the TCP contamination if you determine at a later date that the plume does not come from the Frontier site. However, once the foundation and parking lot are built, sampling will be much more difficult if not impossible in the case of the store concrete slab. Moreover, if the TCP originated from the source area, it changes the nature and scope of the Frontier site clean up and investigation. Specifically, this detection may indicate that the contamination has moved further that previously thought thus requiring reassessment of the pump and treat system and the extent of the groundwater contamination. Therefore, in addition to assessing the extent of the contamination, it is also essential to ascertain its source to the extent possible."

She concludes:

"The issue is not just whether or not Target mitigates for possible TCP intrusion into the store as is currently planned. It is an issue of determining the extent and probable source of the TCP contamination, possible health impacts in the neighborhood and how to remediate if necessary. This is to request that the EPA take immediate action to further investigate the source, extent and movement of the TCP in the groundwater in the vicinity of the planned Target store and adjacent homes. Time of the essence as Target plans to move ahead very soon to build the store foundation."

This is a very concerning situation as the EPA for whatever reason has decided to strike a deal with Target rather than require simple testing to determine the extent of the problem. The question arises, as Target proposes to build on a Superfund cleanup site, how much of a health threat if any, this poses to workers and customers of a new Target.

At this point, this is not a question of preventing Target from going into this location, it is now a question of mitigating whatever environmental and health impacts this choice of sites has. Target won ballot confirmation based on the notion that this would be a new and green Target. They pointed to the fact that this would be the first LEED-certified building. And yet, they seem wholly unconcerned about possible health and environmental impacts are now faced by the community based on decisions made by previous stewards of this property.

Some will argue that if the EPA has little problem with Target going forward neither should we. My concern is of course, the EPA under the Bush administration does not have a stellar record and has consistently sided with industry and commercial interests over environmental protection. As such, it would be interesting to see what a new EPA under an Obama administration would bring. It seems suspicious that the the date certain for beginning the project is January 5 just two weeks and a day before Obama officially and formally becomes President.

As the extent of this health problem is unknown at this time, Davis should demand answers BEFORE work goes forward. If there are no health threats, then Target can by all means, proceed as planned. Why not take the extra time to be sure? Unless of course they know something that we do not.

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